The IRS issued final regulations on the rules to accelerate COD income that taxpayers elected to defer over a five-year period when an applicable debt instrument was reacquired by the issuer or a related party in 2009 or 2010.
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TOPICS
C Corporation Income Taxation
Buying or Selling C Corporation Stock
Unlike an asset sale, a taxable stock sale does not result in the recognition of taxable income or loss at the corporate level, although selling shareholders may recognize taxable gain on the sale of their shares.
Provision of Services by Corporation to Shareholder Not a Constructive Dividend
The Tax Court held that the sole shareholder of a corporation did not receive a constructive dividend when the corporation provided construction services to the shareholder at cost.
Chief Counsel Provides Guidance on Allocating Acquisition-Related Costs
This item summarizes some of the relevant rules that govern the tax years of subsidiaries that join or leave a consolidated group.
2012 Best Article Award
Winners of The Tax Adviser’s 2012 Best Article Award.
IRS Issues Final Rules on Exceptions From REIT or RIC Built-in Gain Recognition
The IRS issued final regulations that provide guidance on the recognition of built-in gain in certain transfers of property from a C corporation to a RIC or REIT.
IRS Changes Schedule M-3 Filing Requirements for Some Entities
The IRS on its website announced changes in the filing requirements for Schedule M-3 for certain corporations and partnerships.
New Method for Determining Who Gets Sec. 199 Deduction Under Contract Manufacturing Arrangements
The IRS issued new guidance regarding how to determine which taxpayer is entitled to claim the Sec. 199 domestic production activities deduction in a contract manufacturing arrangement.
Final Rules on Acceleration of COD Income Deferral Are Issued
The IRS issued final regulations on the rules to accelerate COD income that taxpayers elected to defer over a five-year period when an applicable debt instrument was reacquired by the issuer or a related party in 2009 or 2010.
Questions on EINs in F Reorganizations Involving Disregarded Entities
Until the IRS issues clarifying guidance on whether a corporation that converts to an LLC always must retain its historic EIN, potential procedural conflicts may exist in relying on Rev. Rul. 73-526 to retain an EIN in an F reorganization.
ATRA Allows Taxpayers to Continue to Accelerate Certain AMT Credits
Under the provisions of ATRA, corporations or consolidated groups with AMT credits from pre-2006 tax years may continue to accelerate the use of these credits instead of claiming bonus depreciation for eligible qualified property.
Whether Incentives That Require Companies to Provide Jobs Should Be Treated As Nonshareholder Capital Contributions
Imposition of a jobs requirement should not by itself prevent a subsidy from qualifying as a nonshareholder contribution.
Failing Subchapter C Requirements to Avoid Nonrecognition Treatment
If a transaction satisfies the substantive tests for certain subchapter C nonrecognition provisions, can the taxpayer nonetheless achieve a taxable exchange by intentionally violating procedural requirements?
Options for Compliance With Worker Classification Rules
Determining proper classification of workers, either as independent contractors or employees, can be subjective and a challenge for employers.
LIFO Inventory Considerations When Making a C-to-S Conversion
A taxpayer valuing its inventory under the last-in, first-out (LIFO) method should consider two significant implications for taxable income when converting from a C corporation to an S corporation.
Schedule UTP: Update on IRS Findings
This item provides an overview of the IRS’s statistics on 2010 and 2011 Schedules UTP, Uncertain Tax Position Statement.
Foreign Branch Incorporation: Interaction of OFL, Branch Loss Recapture Rules
This item discusses the interaction between two recapture rules—OFL recapture and branch loss recapture—triggered by a branch incorporation.
Opportunity to Eliminate Certain Intercompany Gain
Groups can effectively eliminate the intercompany gain in certain circumstances, thereby reducing the possibility of inadvertently triggering intercompany gain and freeing taxpayers from the need to plan transactions so as to avoid a trigger.
Entities With Less Than $50 Million in Assets Get New Schedule M-3 Filing Rules
The IRS announced changes in the filing requirements for Schedule M-3, Net Income (Loss) Reconciliation, for certain corporations and partnerships.
Sec. 336(e) Election Regulations Are Issued
The IRS issued final regulations on the rules that apply when an election under Sec. 336(e) is made to treat the sale, exchange, or distribution of at least 80% of the voting power and value of a target corporation’s stock as a sale of all its underlying assets.
TAX PRACTICE MANAGEMENT
2025 tax software survey
AICPA members in tax practice assess how their return preparation software performed during tax season and offer insights into their procedures.
